The IRS has an appeals system for people who do not agree with the results of an
examination of their tax returns or with other adjustments to their tax liability.
If your examination or other adjustment was conducted through a personal interview with
an IRS employee, the employee will explain your appeal rights to you. If you disagree with
the findings, you may request a meeting with the employee's supervisor. If you still do
not reach an agreement, or if the examination or other adjustment was conducted through
correspondence, the IRS will provide you with a report and/or letter explaining the
proposed adjustments and informing you of your right to request a conference with an
appeals officer. The letter will also tell you how to make your request. If you request an
appeals conference, you should be prepared to support your position.
In addition to examinations many other things can be appealed. Among them are
penalties, including the trust fund recovery penalty, offers in compromise, employment tax
adjustments, liens, levies, seizures, abatement of interest and other claims.
Appeals conferences are informal meetings. You may represent yourself at your Appeals
conference; or, if you want, you may have an attorney, a certified public accountant, or
an individual enrolled to practice before the IRS represent you. If you do not reach an
agreement with the appeals officer, or you do not wish to appeal within the IRS, you may
take your appeal into the courts.
For further information on the appeals process and information on how to stop interest
from accruing on any anticipated liability, order Publication 5, Appeal Rights and
Preparation of Protest for Unagreed Cases and Publication
556, Examination of Returns, Appeal Rights and Claims for Refund. Also,
Publication 1660, Collection Appeal Rights (for Liens, Levies and Seizures)
discusses how you can appeal those actions. These publications can be ordered by calling
1-800-829-3676.
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